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June 2010

Issued by:
The Regulation and Supervision Bureau
for the water, wastewater and electricity sector
in the Emirate of Abu Dhabi

2010

Guide to Recycled
Water and Biosolids
Regulations

Guide to
Recycled Water and
Biosolids Regulations 2010
Issued by:
The Regulation and Supervision Bureau
for the water, wastewater and electricity sector
in the Emirate of Abu Dhabi
www.rsb.gov.ae

June 2010

Guide to Recycled Water and Biosolids Regulations 2010

Foreword

Recycled Water and Biosolids


The products of Wastewater treatment are a valuable source of water,
nutrients and energy. The Bureau believes that the Wastewater sector
must promote the Reuse of Recycled Water and Biosolids to support the
Emirates sustainable development goals.
The Bureau issued the Recycled Water and Biosolids Regulations 2010
to establish a legal framework for the safe and economic Disposal of
Recycled Water and Biosolids by Sewerage Service Licensees.
The Regulations aim to control the treatment and Disposal of Recycled
Water and Biosolids in a way that will protect public health, safeguard
the environment, minimise public nuisance and encourage the full
recovery of these valuable resources.

Guidance
The Bureau believes that regulation only achieves its objectives if
Licensees have a clear understanding of what they must do to comply
with the law.
This guidance document is aimed at helping Licensees and Endusers understand their duties under the Recycled Water and Biosolids
Regulations 2010.

Nicholas Carter
Director General

Guide to Recycled Water and Biosolids Regulations 2010

List of revisions

Revision

Date

Prepared
by:

Checked
by:

Issued to:

1.0

June 10

RMS

MG & CH

Publication

Guide to Recycled Water and Biosolids Regulations 2010

Table of contents
1.

Overview
Background
Purpose
Implementation
Interpretation
Help and advice

7
7
7
8
9
9

2.

Introduction
Background
Defining Recycled Water and Biosolids
Scope of the Regulations
Related activities
Regulatory framework

11
11
11
13
14
15

3.

Part 3: Disposal of Recycled Water


and Biosolids
Regulation 3.1 Prohibitions
Regulation 3.2 Discharges to the environment
Regulation 3.3 Self supply schemes

19
19
21
22

4.

Part 4: Supply of Recycled Water and Biosolids


Regulation 4.1 Supply Agreements
Regulation 4.2 Applying for a Supply Agreement
Regulation 4.3 Issue of a Supply Agreement
Regulation 4.7 Supply Agreement details

23
23
23
24
26

5.

Part 5: Safety Plans


Regulation 5.1 Development of Safety Plans
Regulation 5.2 Review of Safety Plans
Regulation 5.3 Scope of Safety Plans

27
27
28
28

6.

Part 6: Safety Plan monitoring programme


Regulation 6.1 Development of a Safety Plan
monitoring programme
Regulation 6.2 Data collection and reporting
Regulation 6.3 Auditing
Regulation 6.5 Monitoring equipment
Regulation 6.6 and 6.7 Sampling and
analytical systems

33
33

Part 7: Compliance
Regulation 7.1 Assessing compliance
Regulation 7.2 Improvement notices
Regulation 7.5 Enforcement

41
41
43
43

7.

Guide to Recycled Water and Biosolids Regulations 2010

34
35
37
37

Table of contents (cont.)


8.

Part 8: Appeals and arbitration


Regulation 8.1 Appeals
Regulation 8.2 Appeal form
Regulation 8.6 Bureau consideration
Regulation 8.8 Arbitration

45
45
46
46
47

9.

Part 9: Demand management


Regulation 9.1 Measuring production and
Regulation 9.2 Measuring supply
Regulation 9.3 Meeting demand
Regulation 9.4 Efficient use

49
49

10.

Part 10: Education and guidance


Regulation 10.1 Education and guidance
Regulation 10.2 Awareness of Recycled Water
and Biosolids quality

51
51
51

11.

Part 11: Recycled Water and


Biosolids Review Panel
Regulation 11.1 Establishment of the Panel
Regulation 11.6 Panel Members
Regulation 11.9 Panel Rules

53

Annexes

Guide to Recycled Water and Biosolids Regulations 2010

49
50

53
53
54
55

Overview

Background
1.1

The Recycled Water and Biosolids Regulations 2010


establish a legal framework for the safe and economic
management of Recycled Water and Biosolids by Sewerage
Services Licensees in the Emirate of Abu Dhabi.

1.2

The Regulations are issued by the Bureau under its powers


defined in Article (62) of Law No (2) which states:

The Regulation and Supervision Bureau may, in


consultation with whom it sees fit, make such Regulations
as it sees fit for the purposes set out in Articles (63) and (68)
of this Law.

1.3

Figure 1.1 illustrates the laws, documents and terms used by


the Bureau when regulating the sector.
Figure 1.1 Sector overview

Guide to Recycled Water and Biosolids Regulations 2010

Purpose

1.4

This guidance document is aimed at helping Sewerage


Services Licensees and End-users understand the
requirements of the Recycled Water and Biosolids
Regulations 2010.

1.5

The guide aims to provide information on:


(a) the approach Licensees should use to develop:
(i)

Supply Agreements for the Disposal of


Recycled Water and Biosolids; and

(ii)

Safety Plans and monitoring programmes; and

(b) the roles and responsibilities of End-users, Licensees,


the Bureau and the Panel.
1.6

The guide has been developed in consultation with


Sewerage Service Licensees, the Environment Agency Abu
Dhabi, The Health Authority Abu Dhabi and the Center of
Waste Management.

1.7

The Bureau will ensure that this document is regularly


reviewed and updated in consultation with the Panel.

Implementation

1.8

Any Disposal activity which begins after the 1 June 2010


must comply with the Regulations immediately.

1.9

Any Disposal activity which is ongoing on 1 June 2010 must


comply with the Regulations by 1 June 2011.

1.10

A Disposal Licensee may agree an alternative programme


for compliance for ongoing Disposal activities with the
Bureau by 1 December 2010.

Guide to Recycled Water and Biosolids Regulations 2010

Overview
Interpretation
1.11

Words which are defined in the Regulations begin with


capital letters when used in this guidance document.

1.12

A word or expression which is defined in the Law and used,


but not defined in this guidance document, has the same
meaning as in the Law.

1.13

All time periods in the Regulations are stated in calendar


days.

Help and advice


1.14

The Bureau welcomes views and comments about the


content and presentation of the Recycled Water and
Biosolids Regulations 2010 and this guidance document.

1.15

Please contact the Bureau if you:

1.16

1.17

(a)

have any questions about the Regulations;

(b)

have suggestions on how we could improve the


Regulations and this guidance document; or

(c)

require copies of the Laws and Regulations which


govern the Wastewater sector.

To contact the Bureau please:


(a)

email: water@rsb.gov.ae

(b)

telephone: +971 (0)2 4439333; or

(c)

write to: Director of Water Services, Regulation and


Supervision Bureau, P.O. Box 32800, Abu Dhabi,
UAE.

Copies of the Laws and Regulations which govern the


Wastewater sector are available electronically on the
Bureaus website http://www.rsb.gov.ae.

Guide to Recycled Water and Biosolids Regulations 2010

10

Guide to Recycled Water and Biosolids Regulations 2010

Introduction

Background
2.1

The Wastewater Sewerage, Treatment and Disposal


Systems in Abu Dhabi have been developed in response
to Government requirements to protect public health
and minimise the environmental impact of Wastewater
discharges. However, the collection and treatment of
Wastewater generates a range of valuable products which
can be used as a source of water, nutrients and energy.

2.2

In order to support the Emirates sustainable development


goals the Bureau has developed a legal framework to:
(a)

maximise the social and economic benefits associated


with Recycled Water and Biosolids Disposal;

(b)

minimise the risk to public health and the environment;


and

(c)

develop public confidence in Recycled Water and


Biosolids Disposal.

Defining Recycled Water and Biosolids


2.3

The Regulations include the following important definitions


(a)

Wastewater the water-borne wastes generated


by any domestic, commercial or industrial activity
including Grey Water and Trade Effluent.

(b)

Grey Water Wastewater sourced solely from baths,


showers, hand basins and domestic laundries.

(c)

Recycled Water treated liquid effluent produced


by a Wastewater Treatment System that is suitable for
Reuse.

(d)

Biosolids sewage sludge produced by a Wastewater


Treatment System that has been treated and stabilised
to the extent that it can be safely supplied for Reuse
activities.

(e)

Disposal the safe and sustainable disposal,


recycling or sale of various products produced from
the Wastewater Treatment System.

Guide to Recycled Water and Biosolids Regulations 2010

11

2.4

The definitions are intended to clarify three key issues:


(a)

Grey Water is an integral component of Wastewater


and its collection, treatment and Disposal are
regulated in the same way as Wastewater. Figure 2.1
illustrates how the Bureau views the components
which make up Wastewater.

Figure 2.1 Wastewater components

12

(b)

Recycled Water and Biosolids are the products of


Wastewater Treatment that have been treated to a
standard which makes them safe to use in applications
which are socially and environmentally beneficial.
They have low levels of microbiological and chemical
contamination and are assessed by their quality not
their source. Figure 2.2 illustrates the points at which
the Bureau believes the products of Wastewater or
Grey Water treatment become Recycled Water and
Biosolids.

(c)

The definition of Disposal is aimed at encouraging


Disposal Licensees to develop outlets for Recycled
Water and Biosolids which are safe, economic and
socially acceptable. The Bureau believes that the
Disposal of Recycled Water and Biosolids includes
the following activities:

Guide to Recycled Water and Biosolids Regulations 2010

1ntroduction

(i)

the management and transfer of Recycled


Water and Biosolids to the Point-of-transfer to
an End-user;

(ii)

the economic, safe and socially acceptable


supply of Recycled Water and Biosolids for
beneficial use; and

(iii)

the discharge of Recycled Water and Biosolids


to the environment.

Figure 2.2 Recycled Water and Biosolids

Scope of the Regulations


2.5

The Regulations define the actions Sewerage Services


Licensees must take to assure the delivery of Recycled
Water and Biosolids to the Point-of-transfer. The main
requirements of the Regulations will be implemented by
Disposal Licensees and enforced by the Bureau. Figure 2.3
illustrates the scope of the Regulations.

Guide to Recycled Water and Biosolids Regulations 2010

13

Figure 2.3 Scope of the Regulations

Related activities
2.6

The Reuse or further treatment of Recycled Water or


Biosolids is controlled by other regulators. Any Entity
who receives Recycled Water or Biosolids from a Disposal
Licensee must seek advice regarding the regulatory
requirements for their activity from either:
(a)

Environment Agency Abu Dhabi (EAD);

(b)

Center of Waste Management Abu Dhabi (CWM); or

(c)

the appropriate Sector Regulatory Authority (SRA)


appointed under the Emirates Environmental Health
and Safety Management System1.

1 http://www.ead.ae/en/portal/ad.ehsms.aspx

14

Guide to Recycled Water and Biosolids Regulations 2010

1ntroduction

2.7

The release of Trade Effluent into a Sewerage System has


the potential to affect the safe and economic Disposal of
Recycled Water and Biosolids and is regulated by the Trade
Effluent Control Regulations 20102.

Regulatory Framework
2.8

2.9

2.10

The Regulations require Licensees to manage Recycled


Water and Biosolids Disposal by:
(a)

implementing Supply Agreements;

(b)

developing Safety Plans;

(c)

completing Safety Plan monitoring programmes; and

(d)

employing education programmes.

The Regulations require the Bureau to:


(a)

set standards for the quality of Recycled Water and


Biosolids at the Point-of-transfer;

(b)

enforce compliance with the Regulations;

(c)

collate Recycled Water and Biosolids production and


supply data; and

(d)

arbitrate in any disputes between Licensees and Endusers.

Figure 2.4 illustrates the key controls and balances defined


by the Regulations.

Regulation & Supervision Bureau (2010) Trade Effluent Control Regulations 2010, RSB Abu Dhabi

Guide to Recycled Water and Biosolids Regulations 2010

15

Figure 2.4 Controls and balances for Recycled Water


& Biosolids Regulations 2010

2.11

Part 3 of the Regulations prohibit the Disposal of Recycled


Water and Biosolids which do not meet the quality standards
defined in Schedules A and B of the Regulations. The
Bureau will determine and review the quality standards in
consultation with the Panel.

16

Guide to Recycled Water and Biosolids Regulations 2010

1ntroduction

2.12

The Regulations require a Disposal Licensee to develop


two important documents for each Disposal activity:
(a)

Supply Agreement defines the terms and


conditions for the supply of Recycled Water or
Biosolids to the End-user.

(b)

Safety Plan defines the operational and


management controls that the Collection, Treatment
and Disposal Licensees will use to safeguard the
quality and quantity of Recycled Water and Biosolids
to the Point-of-transfer.

2.13

The extent of a Disposal Licensees activity is defined by


the Point-of-transfer to an End-user or the point at which
Recycled Water and Biosolids are released by the Disposal
Licensee to the environment.

2.14

Where Recycled Water or Biosolids are transferred to an


End-user the Disposal Licensee must develop a Supply
Agreement and a Safety Plan for the Disposal activity.

2.15

Where a Disposal Licensee is releasing Recycled Water and


Biosolids:

(a) direct to the environment; or


(b) reusing them on their own premises;


they must develop a Safety Plan which covers all Licensee
activities to the point-of-release.

2.16

When a Disposal Licensee supplies Recycled Water or


Biosolids to an End-user at a number of locations or for
a number of uses, they must develop a Supply Agreement
and Safety Plan for each Point-of-transfer.

2.17

Part 4 of the Regulations detail the process for obtaining


a Supply Agreement and the circumstances in which an
Agreement can be varied.

Guide to Recycled Water and Biosolids Regulations 2010

17

18

2.18

The Safety Plan is the process which will ensure Licensees


deliver Recycled Water and Biosolids to the Point-oftransfer in a condition which is safe, socially acceptable and
economic. The requirements for a Safety Plan and Safety
Plan monitoring programme are detailed in Part 5 and Part
6 of the Regulations.

2.19

The Regulations recognise the need for checks and balances


on the powers of Licensees and the Bureau. They include
detailed guidance on:
(a)

the process the Bureau will follow to assess compliance


and manage enforcement (Part 7); and

(b)

the Bureaus process for considering appeals (Part 8).

2.20

Part 9 of the Regulations gives guidance to Licensees on


the allocation of Recycled Water and Biosolids. It also sets
out the Bureaus duty to collate data on the production and
supply of Recycled Water and Biosolids. These measures
are aimed at helping the Emirate allocate these valuable
resources safely, economically and fairly.

2.21

The Bureau believes that education and guidance will


play an important role in achieving the safe and economic
Disposal of Recycled Water and Biosolids. Part 10 of the
Regulations mandates the development of education and
guidance strategies aimed at promoting best practice and
raising awareness.

2.22

The Bureau believes that the regulation of Recycled Water


and Biosolids Disposal must be a dynamic process that
stimulates innovation and is flexible enough to manage new
challenges. Part 11 of the Regulations acknowledges regular
review must be an important element of the regulation
process and establishes the Recycled Water and Biosolids
Review Panel. The Panel will provide advice and guidance
to the Bureau on developments in the management and
regulation of Recycled Water and Biosolids.

2.23

The following chapters provide detailed guidance on each


Part of the Regulations.

Guide to Recycled Water and Biosolids Regulations 2010

Part 3: Disposal of Recycled


Water and Biosolids

Regulation 3.1 Prohibitions


Quality criteria for Recycled Water (Schedule A) and
Biosolids (Schedule B)
3.1

The Regulations prohibit the Disposal of Recycled Water


and Biosolids which do not meet the quality standards set
out in schedules A and B of the Regulations.

3.2

The Bureau has worked with the EAD, CWM and HAAD
to develop standards which are realistic, affordable, and
enforceable. In order to make the assessment process
simple, they only include parameters which can be readily
measured and are relevant to assessing the suitability of the
Recycled Water and Biosolids at the Point-of-transfer.

3.3

The standards define the minimum microbiological,


physical and chemical requirements for Recycled Water
and Biosolids at the Point-of-transfer and were developed
by:

3.4

(a)

following guidance from


Organization (WHO);

the

World

Health

(b)

reviewing a range of international frameworks; and

(c)

following precedents in UAE Federal and Abu Dhabi


Emirate Law.

The WHO guidelines for the safe use of Wastewater, excreta


and grey water3 recommends that Wastewater Reuse
should result in risks to public health which are the same as
those associated with other water uses such as drinking or
swimming. The Bureau has embedded this principle into the
Regulations and believes that aligning the risks associated
with different water uses incorporates Wastewater Disposal
into a set of consistent water management policies for the
Emirate.

http://www.who.int/water_sanitation_health/Wastewater/gsuww/en/index.html

Guide to Recycled Water and Biosolids Regulations 2010

19

3.5

The standards for Recycled Water and Biosolids include


two Reuse standards and additional requirements for
specific applications.
(a)

P1 and B1 are the strictest standards and should


be employed when the end-use is likely to involve
frequent and uncontrolled exposure of the general
public, such as the use of Recycled Water for irrigation
in urban areas or toilet flushing.

(b)

P2 and B2 have been developed for activities which


involve infrequent and controlled public exposure,
such as agricultural irrigation or reprocessing of
Biosolids.

3.6

All the standards will require good source control of


industrial and commercial inputs to the Sewerage System.
This will be achieved through the implementation of the
Trade Effluent Control Regulations 2010 by Collection
Licensees.

3.7

It is anticipated that the:

3.8

20

(a)

P1 standard will require Treatment and Disposal


Systems capable of delivering high quality tertiary
treatment and disinfection;

(b)

P2 standard will require Treatment and Disposal


Systems capable of achieving good quality secondary
treatment and disinfection;

(c)

B1 standard may require a sludge disinfection process


to support the sludge stabilisation requirements of
Schedule B2; and

(d)

B2 will be achieved through a good stabilisation


process that achieves the requirements of Schedule
B2.

The Bureau understands that Disposal of Recycled


Water and Biosolids and its regulation should be regularly
reviewed. The Panel is required to recommend revisions

The Recycled Water and Biosolids Regulations

to the standards after considering local epidemiological


data and developments in international practice for the
management of Disposal activities. The Bureau has a duty
to review any recommendations from the Panel and amend
the Regulations where required.

3.9

An End-user may wish to reduce their operational risks


by using Recycled Water or Biosolids of a higher quality
than that defined in the Regulations. The Bureau believes
that the standards in the Regulations will ensure the sector
produces Recycled Water and Biosolids that are safe and
socially acceptable. Further polishing or processing of the
Recycled Water or Biosolids to reduce operational risks
should be the commercial choice and responsibility of the
End-user.

Disposal of Recycled
Water and Biosolids

Supply Agreements
3.10

The Regulations also prohibit the Disposal of Recycled


Water and Biosolids without a Supply Agreement.

3.11

The principle objective of a Supply Agreement is to define:

3.12

(a)

the terms and conditions for the supply of Recycled


Water and Biosolids; and

(b)

the composition and quantity that will be supplied.

Part 4 of the Regulations define the process for obtaining


a Supply Agreement and the minimum requirements for a
Supply Agreement.

Regulation 3.2 Discharges to the environment


3.13

The Regulations recognise that there will be certain


operational circumstances which will make it necessary for
a Licensee to discharge Recycled Water to the environment
or Biosolids to landfill.

3.14

These discharges will be regulated by the EAD, CWM or


EHSMS sector regulatory authority. Licensees must seek

The Recycled Water and Biosolids Regulations

21

advice from these organisations regarding the requirements


for approval and regulation of these discharges.

3.15

Licensees must also report any discharge of Recycled Water


or Biosolids to the environment to the Bureau. The Incident
Reporting Regulations 2008 define the requirements for
reporting incidents4.

3.16

The Bureau acknowledges that the discharge of Recycled


Water to the environment and Biosolids to landfill is current
operational practice for a number of Licensees and that
these Disposal activities have been permitted by other
regulatory agencies. The Bureau also acknowledges that the
current operational practice reflects capacity or capability
limitations in existing Treatment and Disposal Systems.

3.17

However, the Bureau expects Licensees to support the


Emirates sustainable development goals and to develop a
strategic plan to ensure all Recycled Water and Biosolids are
used in economically efficient, safe and socially acceptable
Disposal activities as soon as practicable.

3.18

Licensees who are discharging Recycled Water to the


environment and Biosolids to landfill on 1 June 2010 should
agree an alternative programme for compliance with the
Bureau by 1 December 2010. The alternative programme
must include details of their proposals to minimise the
discharge of Recycled Water to the environment and
Biosolids to landfill.

Regulation 3.3 Self Supply


3.19

A Treatment or Disposal Licensee may Reuse Recycled


Water or Biosolids on its own premises without a Supply
Agreement if it follows the guidance on allocation in Clause
9.3 and develops a Safety Plan which extends to the pointof-use.

3.20

The Licensee must notify the Bureau of any proposed self


supply scheme and include details of the scheme in the
register of Points-of-transfer required by Clause 9.2.

22

http://www.rsb.gov.ae/PDFs/ind001.pdf

Guide to Recycled Water and Biosolids Regulations 2010

Part 4: Supply of Recycled


Water and Biosolids

Regulation 4.1 Supply Agreements


4.1

Anyone who wants to receive Recycled Water and Biosolids


must apply for a Supply Agreement from a Disposal
Licensee.

4.2

A Disposal Licensee must have a Supply Agreement which


defines the terms of supply for every Point-of-transfer on its
Disposal System. This may mean that certain End-users will
have several Supply Agreements because their operations
occur at many locations and they use the Recycled Water
or Biosolids in a number of ways. Figure 4.1 illustrates this
concept.
Figure 4.1 Requirement for Supply Agreements

Regulation 4.2 Applying for a Supply Agreement


4.3

As part of the application process the applicant will be


asked to provide information about the proposed use and
for details of the business making the application.

Guide to Recycled Water and Biosolids Regulations 2010

23

4.4

The provision of false or misleading information in the


application is contrary to the Law and will be enforced in
accordance with the Law.

4.5

The Disposal Licensee will supply applicants with an


application form that will ensure the information required
to assess the application and produce a Supply Agreement
has been provided.

4.6

The application form will seek information concerning:

4.7

(a)

the full name, address, registered office, company


number and legal status of the applicant seeking a
Supply Agreement;

(b)

the proposed Point-of-transfer and discharge location;

(c)

the nature and purpose of the proposed end-use; and

(d)

the maximum quantity of Recycled Water or Biosolids


that will be required on any one day.

Disposal Licensees will assist applicants with the application


process as required.

Regulation 4.3 Issue of a Supply Agreement

24

4.8

Once a complete application for a Supply Agreement has


been submitted, the Disposal Licensee is required to assess
the application and notify the applicant of the outcome
within 60 days.

4.9

When considering an application for a Supply Agreement


the Disposal Licensee must:
(a)

be satisfied that the End-user has demonstrated the


Disposal activity will meet the requirements of Clause
4.3.1 a; and

(b)

have sufficient Recycled Water or Biosolids to meet


the new demand.

Guide to Recycled Water and Biosolids Regulations 2010

When assessing an application for a Supply Agreement the


Disposal Licensee should:
(a)

determine whether the End-user has obtained


approval for the proposed Reuse activity from the
appropriate regulatory authority, for example, the
EAD, CWM or SRA;

(b)

be aware of its own responsibilities under Emirate


and UAE Federal Law with regard to the protection
of:

(c)

4.11

Supply of Recycled
Water and Biosolids

4.10

(i)

the health and safety of staff and others; and

(ii)

the environment; and

determine which standards in Schedule A and B are


applicable for the proposed Disposal activity.

If the application is successful the Disposal Licensee will


send written notification to:
(a) the applicant, including a copy of the draft Supply
Agreement; and
(b) the Bureau including a copy of the draft Supply
Agreement and Safety Plan.

.
4.12

The applicant has the right to appeal to the Bureau if:


(a)

the Supply Agreement has conditions which it


believes are unreasonable; or

(b)

if an application has been refused.

4.13

The process for appealing Disposal Licensee decisions is


outlined in Part 8 of the Regulations.

4.14

Figure 4.2 illustrates a typical application process.

Guide to Recycled Water and Biosolids Regulations 2010

25

Figure 4.2 Supply Agreement application process

Regulation 4.7 Supply Agreement details

26

4.15

The information which must be included in a Supply


Agreement is set out in Clause 4.7.2.

4.16

The Supply Agreement will include both commercial and


technical clauses and form the basis of the relationship
between the End-user and Disposal Licensee.

4.17

In developing the terms and conditions for a Supply


Agreement the Disposal Licensee should consider any
requirements an End-user may require to fulfil its legal
obligations. For example, the Center of Waste Management
will require End-users handling Biosolids to obtain an
analysis of each batch of Biosolids delivered and this
requirement should be detailed in the Supply Agreement.

Guide to Recycled Water and Biosolids Regulations 2010

Part 5: Safety Plans

Regulation 5.1 Development of Safety Plans


5.1

The Regulations require a Disposal Licensee to develop


a Safety Plan which describes the operational and
management controls that will be used to safeguard the
quality and quantity of the Recycled Water or Biosolids
delivered to each Point-of-transfer on its system.

5.2

The objective of a Safety Plan is to protect public health,


safeguard the environment and minimise any Public
Nuisance associated with the Disposal of Recycled Water
or Biosolids.

5.3

The Safety Plan process is designed to:


(a)

identify and minimise risks associated with the supply


of Recycled Water and Biosolids;

(b)

assess the adequacy of the control measures used to


mitigate the risks; and

(c)

promote discussion and collaboration between


Collection, Treatment and Disposal Licensees.

5.4

The Safety Plan concept recognises that there are many


options for addressing the risks associated with the
Disposal of Recycled Water and Biosolids. By examining
the Sewerage, Treatment and Disposal Systems in detail,
Licensees can identify the most economic and secure way
to protect public health, safeguard the environment and
minimise Public Nuisance.

5.5

In practice, effective risk management will be achieved


by using multiple barriers to exposure in the Wastewater
management chain. These barriers may be treatment
processes, source control programmes, codes of practice
for end-use or training schemes for operators. Figure 5.1
illustrates typical exposure barriers.

Guide to Recycled Water and Biosolids Regulations 2010

27

Figure 5.1 Wastewater management chain


exposure barriers

5.6

Safety Plans are applicable to all Wastewater management


systems regardless of their size and complexity.

Regulation 5.2 Review of Safety Plans


5.7

28

The Bureau will review all Safety Plans to ensure Disposal


Licensees are adopting consistent risk management
practices and addressing scheme specific risks which may
threaten public health or the environment.

Guide to Recycled Water and Biosolids Regulations 2010

Regulation 5.3 Scope of Safety Plans


The Safety Plan should cover the entire Wastewater
management chain that delivers Recycled Water or
Biosolids to the Point-of-transfer. The Safety Plan should
be a living document that evolves over time to address new
risks or changes in the Wastewater management chain.

Safety Plans

5.8

Developing a Safety Plan


5.9

The process for developing a Safety Plan must be


well defined and incorporate the plan-do-check-act
methodology set out in ISO 19011:2003 Guidelines
for quality and environmental management systems for
auditing. This concept should be familiar to Licensees
with formal management systems but, in practice, means a
Safety Plan process must include:
(a)

a System assessment: which identifies the


components and capabilities of the Sewerage,
Treatment and Disposal System and the hazards
associated with delivering Recycled Water and
Biosolids to the Point-of-transfer;

(b)

a risk mitigation process: risk assessment and


implementation of operational and management
controls to address the risks;

(c)

an operational monitoring programme:


operation of a monitoring programme which will
assess the effectiveness of any controls, (see Part 6 of
the Regulations) ; and

(d)

a management and communication system:


the review of monitoring information and the
implementation and communication of improvement
programmes, reporting and training.

Guide to Recycled Water and Biosolids Regulations 2010

29

5.10

Figure 5.2 illustrates an approach to developing Safety


Plans.
Figure 5.2 Safety Plan development process

5.11

5
6

30

There is not a standard method for developing and


implementing a Safety Plan. However, useful advice on
systems and approaches which may help Licensees establish
their Safety Plan process can be found in:
(a)

the World Health Organization guidance on


developing Drinking Water Safety Plans5; and

(b)

the EADs technical guidance for developing


operational environmental management plans6.

http://www.who.int/water_sanitation_health/dwq/wsp_manual.pdf
http://www.ead.ae/_data/global/tgds%20new/tgd_oemp_final.pdf

Guide to Recycled Water and Biosolids Regulations 2010

Through its program of developing Drinking Water Safety


Plans, the Bureau has found that:
(a)

the development and maintenance of Safety Plans


must be properly resourced and financed;

(b)

the resulting Safety Plan must be understood and


supported by senior management and staff;

(c)

the team leading the work should be representative of


all relevant disciplines;

(d)

consultants should not normally design or deliver the


Safety Plans as they are unlikely to have sufficient
knowledge of the Licensees operations and are
unlikely to gain staff acceptance of the outcomes;

(e)

the development of the Safety Plan is not a desk


top exercise; site visits form an essential part of the
process;

(f)

every member of staff has something to contribute,


particularly managers and operators of the Sewerage
and Treatment Systems, customer call handlers and
contractors; and

(g)

existing procedures should not be the starting point


for developing a Safety Plan.

Safety Plans

5.12

Risk assessment
5.13

The risk assessment step in the process requires a clear


and consistent definition of likelihood and consequence.
Annex A outlines a template for assessing risk taken from
the Abu Dhabi EHSMS CoP 05 Risk Management. This
document provides useful advice on risk assessment7.

http://www.ead.ae/_data/global/EHSMS%20Updated/AD%20EHSMS%20CoP%2005.pdf

Guide to Recycled Water and Biosolids Regulations 2010

31

5.14

Risk should be calculated before and after a control is put


in place to assess and validate the controls effectiveness. If
a hazard is not mitigated in the Sewerage System it should
be shown as a hazard entering the Treatment System and
so on through the Wastewater management chain up to the
Point-of-transfer and beyond.

5.15

Good examples of how to assess the risks associated with


Recycled Water Disposal can be found in the Environment
Protection and Heritage Council of Australias guidelines
for the safe use of Recycled Water8.

5.16

Licensees may find the food industrys HACCP (Hazard


Analysis of Critical Control Points) system a useful tool
for assessing risks and establishing appropriate operational
controls and monitoring for Recycled Water and Biosolids
Disposal activities. UK Water have described the HACCP
procedures carried out by UK Water companies in relation
to their Biosolids recycling activities in a useful guide9 which
describes how to apply the technique to a Wastewater
Disposal activity.

http://www.ephc.gov.au/taxonomy/term/39
UK Water (2004), The application of HACCP procedures in the water industry: Biosolids treatment
and use on agricultural land, UK Water, London, UK.

32

Guide to Recycled Water and Biosolids Regulations 2010

Part 6: Safety Plan


monitoring programme

Regulation 6.1 Development of a Safety Plan


monitoring programme
6.1

The Regulations require a Disposal Licensee to establish


a compliance monitoring programme for every Safety
Plan. The monitoring should confirm the effectiveness of
any controls and the quality of the Recycled Water and
Biosolids at the Point-of-transfer.

6.2

Any Treatment or Collection Licensee whose system


is connected to the Point-of-Transfer must support the
Disposal Licensee in the development of the monitoring
program. They are responsible for implementing the
requirements of the programme related to their system at
their own cost.

Risk assessment
6.3

Once the Safety Plan risk assessment has been made, the
Disposal Licensee can design an appropriate sampling and
inspection programme with the high risk activities subject
to the most intensive programmes.

6.4

Good examples of methods for developing risk-based


sampling and monitoring programmes include:

10

(a)

The Environment Protection and Heritage Council


of Australias guidelines for the safe use of Recycled
Water8; and

(b)

The UK Environment Agencys environmental


permitting Regulations operational risk appraisal
scheme10.

UK Environmental Agency (2010), Environmental permitting regulations operational


risk appraisal scheme (Opra for EPR), version 3.5, Environment Agency, Bristol, UK.

Guide to Recycled Water and Biosolids Regulations 2010

33

Monitoring programme
6.5

Details of the compliance monitoring programme must


be set out in the Safety Plan, to meet the requirements of
Clause 5.3.1 of the Regulations. The Bureau expects that
the Safety Plan will include details of:
(a)

the methods and frequency of sampling required;

(b)

the process for reviewing and validating online


monitoring; and

(c)

the schedule of proactive inspections to be completed


by the Licensees.

Regulation 6.2 Data collection and reporting


6.6

34

The Regulations require the Disposal Licensee to collate


monitoring and sampling data for each Safety Plan and to
submit a summary to the Bureau. The Bureau anticipates
that this submission will take place on a regular basis
throughout the year and the Bureau will determine data
management requirements with each Disposal Licensee
once the Regulations are established. Figure 6.1 illustrates
the proposed system.

Guide to Recycled Water and Biosolids Regulations 2010

Figure 6.1 Monitoring program data management

Safety Plan monitoring


programme

Regulation 6.3 Auditing


6.7

A Disposal Licensee is also required to establish whether


Licensees are complying with their monitoring obligations
for each Safety Plan in an annual audit. This may be
completed by an independent third party or by the Disposal
Licensees staff. The audit must consider:
(a)
(b)

6.8

11

the accuracy and reliability of the data collected by


Licensees; and
Licensees performance in fulfilling their obligations
with regard to monitoring activities.

The EHSMS CoP 08 Audit and Inspection11 gives


good general advice on the implementation of an audit
programme. The Bureau anticipates that Disposal Licensees
will ensure that anyone carrying out an audit will have the
necessary knowledge and experience and a clearly defined
role. Figure 6.2 outlines a typical audit plan.

http://www.ead.ae/_data/global/EHSMS%20Updated/AD%20EHSMS%20CoP%2008.pdf

Guide to Recycled Water and Biosolids Regulations 2010

35

Figure 6.2 Audit plan

Source: EAD EHSMS CoP 08 Audit and Inspection

36

Guide to Recycled Water and Biosolids Regulations 2010

6.9

The Bureau believes that online monitoring will allow


Licensees to monitor Disposal activities efficiently, effectively
and lower the overall costs of the monitoring programme.

6.10

The measurement and recording of instanteous and


cumulative daily flows will be an important element of
any monitoring programme. All flow meters must be fit
for purpose and installed and maintained to achieve a
minimum accuracy of 10%.

6.11

The advice given by the UK Environment Agency guide to


flow monitoring12 describes good practice and an assessment
process for establishing whether flow metering installations
meet the desired accuracy targets.

6.12

Safety Plan monitoring


programme

Regulation 6.5 Monitoring equipment

Online monitoring is considered to be any type of


continuous measurement of a substance in Wastewater
and includes the facilities for secure data logging and
downloading. Advice on procedures for establishing
accurate and reliable online monitoring can be found in
the UK Environment Agencys Monitoring Certification
Scheme13.

Regulation 6.6 and 6.7 Sampling and


analytical systems
6.13

The Regulations define the requirement for the collection


and analysis of any samples used to assess compliance and
applies to Licensees.

6.14

The Bureau believes that the reliability of the information


obtained from sampling is critical to a successful compliance
assessment process. It is essential that any sample should
be representative of the discharge, handled in a way which
preserves its composition and analysed in a way which is
accurate and repeatable.

12
13

UK Environment Agency (2008) Minimum Requirements for the Self-Monitoring of Effluent FlowVersion 3.2, London.
http://www.environment-agency.gov.uk/business/regulation/31829.aspx

Guide to Recycled Water and Biosolids Regulations 2010

37

Obtaining a representative sample


6.15

The two most common approaches to sampling Wastewater


are grab sampling and composite sampling. When
considering which to adopt the Licensee should considered
the variability of the source, the nature of the Wastewater
and the parameters under investigation.

6.16

The guidance provided in the following documents


represents good practice in the collection of representative
samples:

(a)

ISO 5667-1, Water qualitySampling, Part 1:


Guidance on the design of sampling programs;

(b)

ISO 5667-2, Water qualitySampling, Part 2:


Guidance on sampling techniques;

(c)

ISO 5667-3 Water qualitySampling, Part 3:


Guidance on the preservation and handling of
samples; and

(d)

the UK Standing Committee of Analysts publication,


The Microbiology of Sewage Sludge (2003) Part 2
- Practices and procedures for sampling and sample
preparation14.

Sample analysis
6.17

The Panel will establish a guidance note outlining the


most appropriate methods of analysis to be adopted for
Wastewater, Recycled Water and Biosolids. In establishing
this guidance the Panel will take account of good
international practice and national standards. The Panel
will review the following sources to establish its guidance:
(a)

14
15

38

the US Code of Regulations, Title 40 Protection of


Environment, Chapter 1 Environmental Protection
Agency, Sub chapter D, Water Programs Part 136
Guidelines for establishing Test procedures for the
analysis of pollutants15.

http://www.environment-agency.gov.uk/static/documents/Research/mss2003__part_2_604558.pdf
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr136_main_02.tpl

Guide to Recycled Water and Biosolids Regulations 2010

6.19

16

the UK Standing Committee of Analysts series


entitled Methods for the Examination of Waters and
Associated materials16.

(c)

guidance from Emirates Authority for Standardization


& Metrology.

Safety Plan monitoring


programme

6.18

(b)

Analysis should be carried out by a laboratory certified to


perform the tests by an independent accreditation body
acceptable to the Bureau such as
(a)

the Emirates Authority for Standardization &


Metrology; or

(b)

United Kingdom Accreditation Service.

In all cases any laboratory used for the analysis of Recycled


Water and Biosolids should conform with the requirements
of ISO 17025:2005 - General requirements for the
competence of testing and calibration laboratories.

http://www.environment-agency.gov.uk/research/commercial/32874.aspx

Guide to Recycled Water and Biosolids Regulations 2010

39

40

Guide to Recycled Water and Biosolids Regulations 2010

Part 7: Compliance

Regulation 7.1 Assessing compliance


7.1

Article (61) of Law No (2) states:

It shall be the duty of the Regulation and Supervision


Bureau to investigate any matter which appears to be
an enforcement matter and which is the subject of a
representation to it (other than where frivolous) by a person
having an interest in the matter. An enforcement matter is
any matter in respect of which any of the functions of the
Regulation and Supervision Bureau under Chapter 3 of
Part 6 of this Law are or may be exercisable.

7.2

In order to fulfil this duty, the Bureau will assess whether


Licensees are complying with the Regulations by reviewing
information submitted by Licensees and by completing site
inspections and audits.

7.3

In assessing compliance, the Bureau will act:

7.4

(a)

Proportionally take account of how far the


Licensee has fallen short of what is required;

(b)

Consistently take a similar approach in similar


circumstances to achieve similar ends; and

(c)

Transparently help Licensees understand what is


expected of them.

Where Licensees are found to be breaching the requirements


of the Regulations, the Bureau will take action to:
(a)

ensure Licensees take action to deal with any breach;

(b)

promote compliance with the Law and deter future


non-compliance;

(c)

change future behaviour of the offender; and

(d)

eliminate any financial gain or benefit associated with


non-compliance.

Guide to Recycled Water and Biosolids Regulations 2010

41

7.5

To achieve these objectives Law No (2) empowers the


Bureau to:
(a) appoint inspectors (Article (60)); and
(b) require compliance with notices issued to prevent or
end a breach of the Regulations or to reduce the risk
of personal injury, property damage and interference
with property (Article (65)).

Inspectors - Article (60) Law No (2)


7.6

Article (60) of Law No (2) states:


(1)

(2)

42

The Regulation and Supervision Bureau may appoint


qualified persons whose duties shall include:
(i)

inspect and test, periodically and in special


instances, plant and equipment belonging to
persons authorised by licence to conduct a
regulated activity;

(ii)

examine, periodically and in special instances,


the desalination of water, the transportation
and supply of water, the generation,
transmission, distribution and supply of
electricity by licensed operators;

(iii)

inspect and test, where required, such plant


and equipment at consumers' premises'; and

(iv)

perform such other functions as the Regulation


and Supervision Bureau may determine.

Those persons conducting a regulated activity shall


be required to afford those persons appointed under
paragraph (1) of this Article unrestricted access to all
plant, equipment and premises used for the purposes
of the regulated activity.

Guide to Recycled Water and Biosolids Regulations 2010

7.7

If the Bureau identifies that a Licensee has breached the


Regulations, it will establish the severity of the breach and
decide appropriate action.

7.8

Regulation 7.2 defines the procedure the Bureau should


follow if it issues an improvement notice.

7.9

An improvement notice may be served at any time and may


require immediate action to resolve a breach. The notice
must be served in writing and fulfil the requirements of
Regulation 7.2

7.10

If the breach poses a significant and immediate threat to


public health or the environment the Bureau may issue a
verbal improvement notice.

Compliance

Regulation 7.2 Improvement notices

Regulation 7.5 Enforcement


Breach of Regulations - Article (66) of Law No (2)
7.11

Any breach of Regulations is punishable under Article (66)


of Law No (2).

7.12

Article (66) states:

Failure of any person to comply with Regulations made


under Article (62) of this Law shall be punishable with a
fine of not less than AED 250,000. In case the same failure
is repeated by such person, the fine is doubled.

Power to make preliminary order - Article (107)


of Law No (2)
7.13

A breach of the Regulations may be considered a breach of


a licence condition which may be addressed by the Bureau
under Article (107) of Law No (2).

Guide to Recycled Water and Biosolids Regulations 2010

43

7.14

Article (107) states:

Subject to Article (110) of this Law, where it appears to the


Regulation and Supervision Bureau that:
(a)

a licensed operator is contravening, or is likely to


contravene any condition of its licence; and

(b)

it is requisite that a preliminary order only be made,

the Regulation and Supervision Bureau shall by a


preliminary order make such provision as appears to it to
be requisite so as to ensure compliance with that condition.

44

Guide to Recycled Water and Biosolids Regulations 2010

Part 8: Appeals and arbitration

Regulation 8.1 Appeals


8.1

The Bureau recognises the need for checks and balances on


the powers of the Disposal Licensee and the Regulations
empower the Bureau to hear appeals from End-users
regarding unreasonable decisions by the Disposal Licensee.

8.2

The Bureau expects that an End-user will have entered


into negotiations with the Disposal Licensee regarding any
dispute before making an appeal. During these negotiations,
the End-user should have explained why they feel unable to
accept the conditions or action. The Bureau would expect
these negotiations to continue to take place once the appeal
is lodged.

8.3

Figure 8.1 illustrate the process for appeals to be resolved by


the Bureau.
Figure 8.1 Appeals process

Guide to Recycled Water and Biosolids Regulations 2010

45

Regulation 8.2 Appeal form


8.4

A template for the Bureaus appeal application form is set


out in Annex B of this guidance document.

8.5

A completed appeal should be submitted to the Bureaus


Head of Legal Services in writing. The application should
be supported by soft copy of all the appeal documents in
Adobe Acrobat (PDF) format.

Regulation 8.6 Bureau consideration


8.6

When the Bureau receives an appeal it will provide copies of


the completed appeal form and supporting documents to all
affected parties. It will then give both the Disposal Licensee
and End-user the opportunity to make representations
regarding the appeal. At this stage it may be possible for the
appeal to be resolved informally by adoption of suggestions
made by Bureau.

8.7

If the dispute cannot be resolved informally, the Bureau


will decide whether to deal with the appeal based on the
written submissions of both parties, or to arrange a private
hearing. This decision will be dependent on the complexity
of the issues at stake and the views of the appellant and the
Disposal Licensee.

8.8

The appeal will normally be decided in light of the Bureaus


understanding of the practical and financial consequences
for both Disposal Licensee and the End-user. Ultimately,
the Bureau must be satisfied that the condition or action is
justified.

8.9

The Bureau will take into consideration

46

(a)

health and safety requirements;

(b)

any substances likely to damage the environment


or harm public health or cause special difficulty or
expense in Treatment and Disposal Systems;

(c)

whether the conditions imposed by the Licensee relate


to legal obligations imposed by the EAD, CWM or
SRA;

Guide to Recycled Water and Biosolids Regulations 2010

the long-term cost implications for the End-user and


Licensees; and

(e)

the timetable for the achievement of these changes.

After consideration of all of these factors, the Bureau will


determine whether the disputed condition or action is
justified and issue a binding determination in writing to all
affected parties.
Appeals and
arbitration

8.10

(d)

Regulation 8.8 Arbitration


8.11

8.12

Any Entity who believes the Bureau has made an


unreasonable decision regarding the enforcement of these
Regulations may refer the matter to arbitration subject to
the terms of Article (67) and Article (130) of Law No (2).
(a)

Article (67) states The court with the appropriate


jurisdiction shall hear disputes relating to Regulations
made under Article (62) of this Law.

(b)

Article (130) states Any dispute arising between


a person conducting a regulated activity and the
Regulation and Supervision Bureau as to any decision
made by the Regulation and Supervision Bureau
shall be determined by arbitration in accordance with
Schedule 2 to this Law.

Schedule 2 of Law No (2) defines the Water and Electricity


Regulatory Arbitration Code which sets out the procedure
for resolving disputes regarding regulated activities.

Guide to Recycled Water and Biosolids Regulations 2010

47

48

Guide to Recycled Water and Biosolids Regulations 2010

Part 9: Demand management

Regulation 9.1 Measuring production and


9.2 Measuring supply
9.1

The Bureau recognises that measuring the production


and supply of Recycled Water and Biosolids is critical to
establishing economic and fair policies for the allocation of
these valuable resources.

9.2

The Regulations require all Treatment Licensees to keep a


register of key data relating to the quantity and quality of
Recycled Water and Biosolids produced by each of their
Treatment Systems. A template for the register can be
found in Annex C.

9.3

The Regulations also require all Disposal Licensees to keep


a register of key data relating to the quantity and quality
of Recycled Water and Biosolids supplied under each of
their Supply Agreements. A template for the register can be
found in Annex D.

Regulation 9.3 Meeting demand


9.4

The Bureau accepts that the allocation of Recycled Water


and Biosolids is a complex process which must be driven by
Government policy and form part of the Emirates strategy
for managing its resources.

9.5

Where there is a clear direction or policy issued by a


higher authority regarding the allocation of Recycled
Water or Biosolids, the Regulations require a Disposal
Licensee to follow that instruction. However, where there
is no instruction the Disposal Licensee should allocate the
resource using Priority Rights.

9.6

The Priority Rights concept has been used to allocate water


resources in the western United States of America for many
years. It recognises that all Entities have the right to use
water for beneficial purposes and that water allocation
should not be governed by ownership of land with access to
the water resource. In a Priority Rights system, allocation is
decided by the timing of the application for the right to use
the water.

Guide to Recycled Water and Biosolids Regulations 2010

49

9.7

Adopting this approach means that the first Entity to be


given rights to use the Recycled Water or Biosolids for
beneficial purposes acquires the right to its future use in
preference to later applicants.

9.8

When considering an application for a Supply Agreement,


a Disposal Licensee must be satisfied that:

9.9

(a)

the Recycled Water or Biosolids will be used for


beneficial purposes; and

(b)

that the new Supply Agreement will not exceed its


capacity to meet its existing supply obligations.

Under the system, an allocation of the Recycled Water or


Biosolids can only be held by an End-user as long as the use
remains socially or environmentally beneficial and efficient.
If an Entity is not using all their allocation for beneficial
use or in an inefficient way, its allocation could be modified
or lost through a variation of its Supply Agreement by a
Disposal Licensee.

Regulation 9.4 Efficient use


9.10

50

The Regulations require Disposal Licensees to promote


efficient use of Recycled Water and Biosolids. This should
be addressed in the codes of practice for the Reuse of
Recycled Water and Biosolids which all Disposal Licensees
must develop to comply with their licence.

Guide to Recycled Water and Biosolids Regulations 2010

Part 10: Education


and guidance

10

Regulation 10.1 Education and guidance


10.1

International experience has shown that active engagement


with the public helps to address perception issues and
increase community awareness. By increasing awareness
and knowledge of Recycled Water and Biosolids the sector
can improve social acceptance of Reuse practices and help
the community act responsibly.

10.2

End-user education is an essential component of Disposal


activities and limits inadvertent or unauthorised uses of
Recycled Water or Biosolids. The Bureau believes such
programmes will help End-users understand the potential
public health and environmental impacts associated with
unauthorised use or exposure.

10.3

The Bureau will work with Disposal Licensees to help them


develop consistent and appropriate strategies to educate
End-users and the general public.

10.4

Guidance on good practice for engaging End-users and


the general public can be found in Environment Protection
and Heritage Council of Australia Guidelines for water
recycling: managing health and environmental risks
(phase 1) 20068.

Regulation 10.2 Awareness of Recycled Water


and Biosolids quality
10.5

The Bureau believes that the End-user should understand


the value or costs associated with using Recycled Water
and Biosolids. The Regulations require Disposal Licensees
to provide information to End-users which allows them to
make this assessment.

10.6

A Disposal Licensee should define the agronomic value of


the Recycled Water and Biosolids by specifying, amongst
other things, the:
(a)

typical range of total and available nitrogen,


phosphorus and potassium; and

Guide to Recycled Water and Biosolids Regulations 2010

51

(b)

(c)

10.7

10

52

the salinity of the Recycled Water by providing data


on:
(i)

Salinity (dS/m @ 25oC);

(ii)

Total Dissolved Solids (TDS);

(iii)

Sodium Adsorption Ration (SAR);

(iv)

Sodium (Sodium (Na+);

(v)

Chloride (Cl-); and

(vi)

Boron; and

the typical range of the dry matter and volatile matter


in Biosolids.

A Disposal Licensee should define the quality of Recycled


Water for industrial uses by specifying the typical
concentrations of chemicals likely to cause corrosion or
scaling, including but not limited to:
(a)

calcium salts (carbonate, sulphate and phosphate);

(b)

magnesium salts (carbonate and phosphate);

(c)

silica; and

(d)

Total Dissolved Solids.

Guide to Recycled Water and Biosolids Regulations 2010

Part 11: Recycled Water


and Biosolids Review Panel

11

Regulation 11.1 Establishment of the Panel


11.1

The Bureau believes that regulation is a dynamic process


and regular review of the legal framework is important to
encourage innovative, economic and safe management of
Disposal activities.

11.2

The Bureau recognises that stakeholders have an important


part to play in this review process and the Regulations
establish a Panel of expert stakeholders to advise the
Bureau on specific aspects of Recycled Water and Biosolids
Disposal.

Regulation 11.6 Panel members


11.3

The Panel will be made up of representatives from:


(a)

the Bureau;

(b)

all Sewerage Services Licensees with a permanent


licence;

(c)

Government agencies responsible for the protection


of the environment and public health;

(d)

Entities which represent End-users; and

(e)

expert advisers.

11.4

Sewerage Services Licensees with a permanent licence are


detailed on the Bureaus website.

11.5

The following government agencies will be invited to be


members of the first panel
(a)

The Environment Agency Abu Dhabi;

(b)

Health Authority Abu Dhabi;

(c)

Abu Dhabi Food Control Authority;

(d)

Center of Waste Management; and

(e)

The Centre of Environmental Health and Safety


Management.

Guide to Recycled Water and Biosolids Regulations 2010

53

11.6

11

The following Entities which represent End-users will be


invited to be members of the first Panel:
(a)

Department of Municipal Affairs; and

(b)

ZonesCorp.

11.7

The Bureau will establish working groups of Panel members


to address the Panels obligations under the Regulations
and each working group will be made up of five members
including a Bureau chairman.

11.8

When the Bureau establishes a working group it will consider


the qualifications, and experience of all Panel members
and the organisations they represent before selecting a
group which it believes will provide robust, objective and
fair advice.

11.9

The Regulations require that a person nominated to serve


on the Panel must:
(a)

be qualified and competent; and

(b)

have authority to undertake any actions on behalf of


the organisation they represent.

Regulation 11.9 Panel rules


11.10

54

The Panel must develop its own rules and procedures of


governance which must be approved by the Bureau.

Guide to Recycled Water and Biosolids Regulations 2010

ANNEXES

Annexes
Annex A: Risk assessment

58

Annex B: Proposed Bureau Appeal Form

64

Annex C: Treatment Licensee Demand


Management Report

68

Annex D: Disposal Licensee Demand


Management Report

Guide to Recycled Water and Biosolids Regulations 2010

70

57

Annex A

Risk assessment

58

Guide to Recycled Water and Biosolids Regulations 2010

Annex A: Risk assessment


A.1

The risk assessment process must use clear and detailed


definitions of likelihood and consequence.

A.2

The EAD has established guidance for risk assessment in


the EHSMS CoP 05 Risk Management. The following
tables summarise the EHSMS CoPs approach assessing
probability, consequence and risk. These tables provide
clear detailed definitions and could be used as a template
for a Safety Plan risk assessment.

Table A.1 Risk assessment


Consequence
Likelihood

Insignificant (1)

Minor (2)

Moderate (3)

Major (4)

Catastrophic(5)

(1)

Possible (2)

10

Likely

(3)

12

15

Often

(4)

12

16

20

Frequent (5)

10

15

20

25

Rare

Table A.2 Risk categories


Risk Score

Risk Category

Action

15 25
Extreme

Activity should not proceed in


current form

8 14
High

Activity should be modified


and subject to detail analysis

4 - 7
Moderate

Activity can operate subject to


management control or modification

1 - 3
Low

No action required unless


escalation of risk is possible

Table A.3 Likelihood assessment


Probability

Description

Rare

less than once every 5 years

Possible

once in 5 years

Likely

1 to 5 times per year

Often

5 to 12 times per year

Frequent

continuous or regular occurrence

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60

Occasional damage
by erosion or some
disruption to habitats

Occasional short
disruption of aquatic
fauna and flora

Aquatic ecosystems

Insignificant

Land ecosystem

Area Impacted

Short term impacts


on water resources

No impact on water
resources

Limited (<1
year) damage to
ecosystem

Temporary (<1
month) damage or
disruption to fauna
and flora
Significant localised
impacts without
long term affects on
ecosystems.

Temporary but
widespread damage
to land that can be
remediated

Limited damage
to small area of no
significant value.

Temporary (<1
month) damage or
disruption to aquatic
fauna and flora but
no negative impacts
on ecosystem
function.

Changes to fauna
and flora populations
including death of
some rare species
but not eradication.

Moderate

Impact on fauna
and flora but no
negative impacts on
ecosystem function.

Minor

Major

Guide to Recycled Water and Biosolids Regulations 2010


Limited impacts on
water resources

Widespread impact
on fauna and flora of
moderate duration

Permanent and
widespread damage
to land

Major disruption
to fauna and flora
including death of
rare species

Continuous and
serious damage by
erosion.

Table A.4 Consequence assessment

Long term impacts


on water resources

Damage to extensive
proportions of
aquatic ecosystem.

Widespread
destruction to a
significant area of
land

Long term or
permanent change in
fauna and flora with
negative impact on
ecosystem function.

Catastrophic

Cultural heritage

Minot repairable
damage to common
place structures

Moderate damage
to structures and
items of cultural
significance

Significant
infringement of
cultural values

Minor infringement
of cultural values

Generation of
significant quantities
of hazardous waste

Significant nuisance
from noise, odour,
greenhouse gases,
vibration or visual
impact

Moderate

Minor repairable
damage to structures
or items of cultural
significance

Significant use of
natural resources

Minor use of natural


resources

Generation of
significant quantities
of non hazardous
waste

Minor environmental
impact due to
contained release
of pollutants with no
lasting detrimental
effects

Temporary nuisance
from noise, odour,
greenhouse gases,
vibration or visual
impact

Atmosphere, waste
and other

Minor

Insignificant

Area Impacted

Significant
infringement of
cultural values

Major damage
to structures and
items of cultural
significance

Major environmental
impact due to
uncontained release
of pollutants

Major

irreparable damage
to highly valued
structures, items or
locations of cultural
significance

Generation of
significant quantities
of intractable waste

Extensive persistent
discharge of
hazardous pollutant

Catastrophic
environmental impact
due to uncontained
release of pollutants

Catastrophic

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Annex A

62

Insignificant impact
on surrounding
Communities

Incident unlikely to
cause production
loss

Production loss

Insignificant

Health effects

Area Impacted

Production loss up
to one week

Minor exposure
during non routine
activities, maximum
occurrence limited to
twice per year

Minor

Production loss
greater than one
week but less than
one month

Significant emissions
or discharges
that impact on
surrounding
community

Moderate

Production loss
of more than one
month

Major ongoing
health effects likely
for surrounding
communities and
workers

Major

Table A.4 Consequence assessment (cont.)

Loss of licence to
operate or ability to
produce indefinitely

Extreme health risks


and potential for
death

Catastrophic

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Guide to Recycled Water and Biosolids Regulations 2010

63

Annex B

Bureau Appeal Form

64

Guide to Recycled Water and Biosolids Regulations 2010

Annex B: Proposed
Bureau Appeal Form

Recycle Water and Biosolids Regulations 2010


Appeal against Disposal Licensee decision
relating to a Supply Agreement

A) Company responsible for receiving Recycled Water


or Biosolids.
Company name
Registered address
Registered company Number
Principal contact and contact details

B) Disposal Licensee
Company name
Principal contact and contact details

C) Details of Supply Agreement


Supply Agreement reference number
Safety Plan reference number
Physical location of Point-of-transfer

D) Decision to be appealed
Provide a short summary of decision which is being appealed.
Provided a detailed justification for the appeal. Include details of the
technical, procedural or legal challenges which give rise to the appeal.
Append a copy of the following documents:
(a)
(b)
(c)

the Supply Agreement application ;


the Supply Agreement;
the variation notice where issued.

The Recycled Water and Biosolids Regulations

65

Declaration
I confirm that the information contained in this appeal is, to the best of
my knowledge, accurate, comprehensive and not misleading.

I am aware that making an appeal that is known to be false in material


or calculated to mislead is contrary to the Law and shall be enforced
in accordance with Article (66) of Law No (2) of 1998 concerning the
regulation of the water and electricity sectors in the Emirate of Abu
Dhabi, as amended.
Signed by
Print name
Designation
Date
for and on behalf of the Company
Address :
"Enter details of physical address"
Postal address:
"Enter details of postal address"
Telephone: "enter number"
Facsimile: "enter number"
"Stamp with Company seal"

66

Guide to Recycled Water and Biosolids Regulations 2010

Guide to Recycled Water and Biosolids Regulations 2010

67

Annex C

Treatment Licensee
Demand Management Report

68

Guide to Recycled Water and Biosolids Regulations 2010

Guide to Recycled Water and Biosolids Regulations 2010

Total Annual Flow Ml


Mean Daily Flow Ml/d

Total Annual Flow Ml


Mean Daily Flow Ml/d

% meeting P1
% meeting P2
% meeting P3

Total Annual TDM


Av Daily TDM/d

Total Annual TDM


Av Daily TDM/d

Total Annual TDM


Av Daily TDM/d

% meeting B1
% meeting B2

Recycled water
to Reuse off site

Recycled water
to ocean or desert

Recycled
water quality

Biosolids to
direct Reuse

Biosolids to
further processing

Biosolids
to Landfill

Biosolids quality

TDM = Tonnes Dry Matter

Total Annual Flow Ml


Mean Daily Flow Ml/d

Recycled water
to Reuse off site

Notes:

Total Annual Flow Ml


Mean Daily Flow Ml/d

Incoming flow

Wastewater Treatment Works

Works A

Works B

Period from. to ..

[Treatment Licensee]

..

Total

Annex C:
Treatment Licensee
Demand Management Report

69

Annex D

Disposal Licensee
Demand Management Report

70

Guide to Recycled Water and Biosolids Regulations 2010

Guide to Recycled Water and Biosolids Regulations 2010

% meeting P1
% meeting P2
% meeting P3

Total Annual TDM


Av Daily TDM/d

% meeting B1
% meeting B2

Recycled water
quality supplied

Biosolids
quantity supplied

Biosolids
quality supplied

TDM = Tonnes Dry Matter

Total Annual Flow Ml


Mean Daily Flow Ml/d

Recycled water
quantity supplied

Notes:

GPS location
End-Use
Treatment works
source

Disposal sites

Point-of-transfer A

Point-of-transfer B

Period from. to ..

[Disposal Licensee]

Point-of-transfer ..

Total

Annex D:
Disposal Licensee
Demand Management Report

71

Regulation and Supervision Bureau


for
the water, wastewater and electricity sector
in the Emirate of Abu Dhabi
P.O. Box: 32800 Abu Dhabi, U.A.E
e-mail: bureau@rsb.gov.ae
www.rsb.gov.ae

Publication No. ER/P04/010

Guide to Recycled Water and Biosolids Regulations 2010

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